Closing clinical trial accounts



Table of contents

Overview of the closure process 2

Overview 2

Division tasks 3--6

Items needed by SPFA to confirm project termination 3

Requesting information from the Primary Research Coordinator 3

Ensuring all funds have been received 4

Determining residual funds, deficits, or 0 balances 4

Calculating residual funds to be transferred to the residual account(s) 4

Calculating deficits to be transferred to the residual account(s) and impact on RIF accounts 4

Evaluating residual fund level 4

Creating the Principal Investigator close-out memo 5

Scanning the close-out packet 5

Emailing the close-out packet 5

Monthly reconciliation for PI 5

Departmen Chair Research Office tasks 6

Department Chair Research Office close out packet quality check 6

CROPS update by Chair Research Office 6

Department Chair Research Office close-out authorization e-mail 6

Memos and forms 7-10

E-Mail to Primary Coordinator 7

PI Clinical Trials Close-Out Memo 8

PI Clinical Trials Close-Out Memo for Projects with Start-Up Cost Recovery Only 9

Clinical trials pending SPFA closure form 10

Clinical trials close-out checklist 11

Overview of the closure process:

After a clinical trial has been completed, the speedtype needs to be closed and residual funds (minus F&A) need to be transferred to an approved account, or deficits covered by another account. The Financial Coordinator or UBM closing the speedtype gathers and e-mails documents to the SPFA office verifying the close-out, and the Controller’s Office will “zero-out” the speedtype (transfer remaining funds to another speedtype so the clinical trial speedtype balance is $0), and then inactivate the chartfield so no new charges can hit. This e-mail is also copied to the Department of Medicine Research Coordinator so the Chair can e-mail closure authorization, and to the Industry Contracts Office for their records. After all of the processes have occurred in the Sponsored Programs Financial Administration (SPFA) office, the chartfield is inactivated and closed.

Division tasks:

Items needed by SPFA to confirm project termination:

← Sponsor close-out letter: at the end of the study, the sponsor sends the Principal Investigator a letter confirming that the project is ending and that all payments have been issued. SPECIAL NOTE: if a study is old, or if someone who didn’t work on the study is trying to close it, there may not be a sponsor close-out letter. If that’s the case, the IRB termination letter (below) can be used instead but the closure memo must state The sponsor close-out letter for this study could not be located so please use the attached IRB termination letter as closure documentation.

← Institutional Review Board (IRB) termination letter: the IRB issues a letter when they have closed a study within their system, and this must be included in the packet.

← Residual account(s) that funds will be transferred to: each Division needs to determine how they want to handle this. Some use PI-specific D accounts; some use Division-level D accounts; and some use both.

← Principal Investigator (PI) close-out memo: this memo must be drafted by the person closing the study and must be signed or initialed by the PI and the Clinical Financial Manager as confirmation by the PI that the study is closing and all financial activity is complete. Attached are two approved memos: one for regular trials and one for those that closed before enrollment and only start-up costs were recovered.

Requesting information from the Primary Research Coordinator:

For most Divisions, the Primary Research Coordinator on this study will be your link to the sponsor and the IRB, and will provide you with the information you need to close the project.

← Open a new e-mail

← To: address it to the Primary Research Coordinator

← CC: address it to the PI for the trial

← Subject line: type in [Chartfield] [Sponsor] project closure info request (e.g., if it is a Glaxo study and the chartfield is OGMB091022 you would type OGMB091022 Glaxo project closure info request).

← Body: copy and paste the following:

I am beginning the process to close the referenced trial. Please confirm via return e-mail that all monitor visits have occurred, all queries have been resolved, all expenses have been charged, and all funds have been received from the sponsor. Please also e-mail me a scan of the sponsor close-out letter and the IRB termination letter. Thank you.

← Send the e-mail and record it by whatever method you use to track pending e-mails.

← Once you receive the response from the Primary Coordinator, save it, as you will need it and the attachments later in this process.

Division tasks:

Ensuring all funds have been received:

As a quality check that all funds have been received from the sponsor, you will need to check that no accounts receivable are still outstanding:

← Go to University Reports and click on the Financials folder on the left side of the screen.

← Double-click on the Financials – Individual Reconciliation folder.

← Double-click on the CONT 15B ledger_summary_projgrnt and a dialog box will open:

← Period: use the drop-down arrow to select the current month.

← Proj/Grnt ID: fill in the chartfield for this project, e.g., OICN091069.

← Fiscal year: use the drop-down arrow to select the current fiscal year and then click on the OK button at the bottom of this box.

← Look at the top of this page, in the Assets section, on the 130105 Accounts Receivable line, in the TOTAL YTD BALANCE column. This should be 0. If it isn’t, then that means that you’re still waiting to receive funds from the sponsor. Contact the sponsor or Research Coordinator to investigate if there are specific issues to the outstanding balance. If the funds will not be paid, then e-mail Dottie Davidson in SPFA at dmdavi12@louisville.edu to remove the outstanding A/R balance. The e-mail will need to include a justification. If the funds are still pending payment, the account cannot be closed until all funds have been received.

Determining residual funds, deficits or 0 balances:

You now must determine how much residual funding or deficit exists in the account:

← Refer to the CONT 15B report you just ran.

← Look at the top of this page, in the Assets section, on the Bank 1 – Cash Consolidation line, in the TOTAL YTD BALANCE column. If there are no parentheses around this number, this is how much residual funds are left. If there are parentheses, this is the amount that the account is in deficit. If the amount is 0, that means there is nothing to be transferred (usually this means that the trial was closed before subject enrollment.)

Calculating residual funds to be transferred to the residual account(s):

← Because indirect costs will be deducted from residual funds, you can determine the actual amount that will be transferred to the residual fund account by dividing the current balance by 1.26 (e.g., if there is $1,000 left, divide this by 1.26 and you will get $793.65). When this account is closed, the $793.65 will be added to the residual account and the remaining $206.35 will be charged to F&A.

Calculating deficits to be transferred to the residual account(s) and impact on RIF accounts:

← You calculate deficits the same as residuals, however, the indirect costs are withdrawn from RIF accounts instead of deposited.

Evaluating residual fund level:

← PI and staff salary expenditures: If no salary and fringe were charged to the project, SPFA will not close the account.

← Minimal expenses: If the residual amount exceeds expenses by more than 20%, SPFA will not close the account.

Division tasks:

Creating the Principal Investigator close-out memo:

← Download the PI CLINICAL TRIALS CLOSE-OUT MEMO, or the PI CLINICAL TRIALS CLOSE-OUT MEMO FOR PROJECTS WITH START-UP COST RECOVERY ONLY

← DATE: change to today’s date.

← TO: highlight [Accountant name] and fill in the name of the accountant assigned to this project (e.g., Thomas Furrie)

← FROM: highlight [PI name] and fill in the PI’s name and then [Clinical Financial Manager or UBM] and fill in your name

← SPEEDTYPE: highlight [D speedtype #, or Dept or PI RIF #] and fill in the speedtype you’re transferring the funds to.

← For deficit transfers: if you are transferring a deficit to your residual account, change the words residual funds in the first sentence to deficits.

← Save, print and initial the memo and then forward to the PI to initial.

Scanning the close-out packet:

← Gather the items in this order: 1) PI close-out memo; 2) Sponsor close-out memo or IRB memo; and 3) IRB termination letter.

← Scan and title the PDF file [Chartfield #] close-out packet.

E-mailing the close-out packet:

← Create a new e-mail.

← To: address this to the accountant in the SPFA office assigned to this project (NOTE: if you don’t know who this is, you can run the University Report CONT 03B and the accountant will be named at the top.)

← CC: address to MedResearch@louisville.edu, to the PI and to Service Account Industry Contracts.

← Subject: fill in [Chartfield #] speedtype closure.

← Body: fill in the following: Attached you will find the close-out materials needed to close the referenced chartfield. Please e-mail me once the JV has been processed to transfer these funds. The Chair’s Office will follow this e-mail with a close-out authorization e-mail. Thanks.

Monthly account reconciliation for PI:

Once the close-out materials are sent to SPFA, you won’t have to complete the usual monthly account reconciliation. Instead, just complete the attached Clinical trials pending closure by SPFA and e-mail to the PI each month.

Department Chair Research Office tasks:

Department Chair Research Office close-out packet quality check:

← PI close out memo:

← Check that it follows the format in the attached close-out memo template.

← Signed/initialed by both PI and Clinical Financial Manager.

← Sponsor close-out memo:

← Included, or PI close out memo states that it was not available and the IRB termination letter subs for it.

← IRB termination letter:

← Included

← Financials check:

← Run the CONT-15B report for this project to determine if there are residual funds or deficit.

← If there is a deficit in the project account, run the CONT-15A report for the account to which the deficit is being transferred to ensure there are sufficient funds to cover. If not, do a Reply All to the e-mail and state This close-out cannot be processed as this project is in deficit and there are insufficient funds in the account to which the deficit is being transferred to cover the deficit. Please advise. Thanks

CROPS update by Chair Research Office:

← Change Project status to Closed-pending Chair’s authorization (TBD as CROPS is developed)

Department Chair Research Office close-out authorization e-mail:

← The Research Office will do a Replay All to the close-out e-mail, add the Chair as of the recipients, and copy and paste the following into the body: Dr. Roman, I have reviewed the close-out materials and financials and they meet our requirements. Please e-mail a Reply All to this e-mail to authorize this close-out. Thanks.

← The Chair Research Office will file the e-mail in the Chair close out pending folder.

← The Chair will send a return e-mail authorizing close out.

← The Chair Research Office will change the CROPS Project Status to Closed-pending SPFA close-out.

← The Chair Research Office will create a new e-mail folder in the SPFA close outs pending folder and title it [Chartfield] [Division][Date Chair e-mailed authorization] (e.g., if the Chair sent his e-mail authorization for the Chartfield OICB091099 on 3/1/11 for a Pulmonary trial, the folder title will be OICB091099 Pulmonary 3-11-11).

E-MAIL TO PRIMARY COORDINATOR

SUBJECT:

OICN123456 project closure info request

MESSAGE:

I am beginning the process to close the referenced trial. Please confirm via return e-mail that all monitor visits have occurred, all queries have been resolved, all expenses have been charged, and all funds have been received from the sponsor. Please also e-mail me a scan of the sponsor close-out letter and the IRB termination letter. Thank you.

Thank you.

PI CLINICAL TRIALS CLOSE-OUT MEMO

DATE: [TBD]

TO: [Accountant name], Sponsored Programs Finance Administration

Service Account Industry Contracts

Department of Medicine Research Office

FROM: [PI name]

[Clinical Financial Manager or UBM]

RE: [Chartfield number] speedtype closure

Please accept this memo as authorization to close the referenced speedtype and to transfer all residual funds to speedtype [D speedtype #, or Dept or PI RIF #]. Attached are both the sponsor close-out letter and IRB termination letter verifying this project has ended. We have verified that all research has been completed; the speedtype can be closed; all applicable expenses have been received and posted; all revenues have been received and posted; all necessary cost transfers have been posted; and all invoices for payments to hospitals and affiliates have been paid.

Thank you.

PI CLINICAL TRIALS CLOSE-OUT MEMO FOR PROJECTS WITH START-UP COST RECOVERY ONLY

DATE: [TBD]

TO: [Accountant name], Sponsored Programs Finance Administration

Service Account Industry Contracts

Department of Medicine Research Office

FROM: [PI name]

[Clinical Financial Manager or UBM]

RE: [Chartfield number] speedtype closure

Please accept this memo as authorization to close the referenced speedtype and to transfer all residual funds to speedtype [D speedtype #, or Dept or PI RIF #]. This project closed before subjects were actually enrolled so only start-up costs have been recovered. Attached are both the sponsor close-out letter and IRB termination letter verifying this project has ended. We have verified that all research has been completed; the speedtype can be closed; all applicable expenses have been received and posted; all revenues have been received and posted; and all necessary cost transfers have been posted.

Thank you.

|Clinical trials pending closure by SPFA |

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Clinical trials closure checklist:

1. E-mail research coordinator for closure materials:

← Subject line: Chartfield # Sponsor project closure info request

← Body: I am beginning the process to close the referenced trial. Please confirm via return e-mail that all monitor visits have occurred, all queries have been resolved, all expenses have been charged, and all funds have been received from the sponsor. Please also e-mail me a scan of the sponsor close-out letter and the IRB termination letter. Thank you.

2. Check that all funds have been received:

← Run CONT 15 b report and check that line 1301015 Accounts Receivable is 0.

← If not 0, check with PI to see if specific issues need to be resolved. If not, e-mail Dottie Davidson at dmdavi12@louisville.edu request and justification to remove deficit.

3. Determine residual funds, deficits or 0 balances:

← On CONT 15 b report and check Assets line Bank 1 – Cash Consolidation, TOTAL YTD BALANCE column.

← Parentheses around number: residual funds left

← No parentheses: deficit amount

← NOTE: if the income was more than 20% of the expenses or little or no salary expenses were charged, SPFA is going to question you about this.

4. Calculate residual funds or deficits:

← Divide current balance by 1.26 to come up with direct funds to be transferred (rest will go to F& A and if a deficit 10% of remaining will be deducted from both PI and Dept. RIF accounts).

5. Create PI close-out memo:

← Use one of the sample memos.

← Change date

← To: Fill in Accountant’s Name

← From: Fill in PI and your name

← Speedtype: fill in

← Print, initial, have PI initial and scan

6. Scan close-out packet:

← PI closure memo, Sponsor close-out letter & IRB close-out letter and save as Chartfield # close-out packet.

7. E-mail close-out packet:

← To: SPFA accountant

← CC: PI, MedResearch@louisville.edu & indcontr@louisville.edu

← Subject line: Chartfield # speedtype closure

← Body: Attached you will find the close-out materials needed to close the referenced chartfield. Please e-mail me once the JV has been processed to transfer these funds. The Chair’s Office will follow this e-mail with a close-out authorization e-mail. Thanks.

8. Follow-up:

← Chair’s Research Office: will send e-mail to Chair within 48 hours requesting authorization.

← Chair: will send authorization e-mail within 48 hours after Research Office.

← SPFA: will close-out within 3-6 months.

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